The proposed settlement, which will be considered by the Nevada Gaming Commission on Thursday, is related to a scheme that led to Wynn forfeiting $130.1 million in a nonprosecution agreement with the U.S. Attorney’s Office for the Southern District of California and the U.S. Department of Justice to end an investigation in September.

“We are pleased that we have resolved this matter with the Nevada Gaming Control Board, which is the same matter Wynn Las Vegas resolved with the U.S. Attorney’s office in September 2024,” Wynn Resorts said in a statement. “Wynn Resorts is committed to acting with the highest integrity and in full compliance with all laws and regulations governing our industry. The improper actions that are the subject of the settlement, which violated Wynn’s own compliance policies and procedures, were undertaken by individuals with whom we severed ties years ago. We accept responsibility for those actions and are now glad the matter will soon be fully resolved.”

The stipulation for settlement posted late Thursday says the company will continue to maintain its anti-money-laundering program, retain all records related to AML training and continue to maintain AML training materials for its independent agents.

Wynn’s internal audit team will be required to review, evaluate and report on the company’s compliance with its AML program with a report due in two years. Changes in the program must be reported to regulators.

The stipulation also requires Wynn to maintain an appropriate number of employees dedicated to AML compliance and provide reports on any changes within five business days.

Employees responsible for the illegal activity were fired by the company, which stated in the stipulation for settlement that “Wynn Las Vegas has worked hard over the last 20 years to develop and foster a strong culture of compliance, with the goal of achieving a ‘best-in-class’ compliance program.”

The company committed to a compliance-first mindset by frequently hosting formal and informal meetings with employees to reinforce its commitment to excellence.

“Unfortunately, a few former employees failed to adhere to the company’s clear compliance directives by allowing certain customers and independent agents to engage in the unlawful conduct as described in the complaint that clearly violated Wynn Las Vegas policies and procedures,” the company said in the stipulation. “Wynn Las Vegas immediately commenced an internal investigation and separated not only the employees involved in the misconduct, but also several employees who were aware of the misconduct and did not report it to Wynn Las Vegas, as required under the AML program.”

New executive team

Since the incidents occurred as early as 2016, Wynn has built a new executive team headed by CEO Craig Billings, Chief Financial Officer Julie Cameron-Doe, General Counsel Jaqui Krum, Chief Operating Officer Brian Gullbrants and Chief Global Compliance Officer Omar Khoury, none of whom served in those positions during the conduct described in the Control Board complaint.

The company also reconstituted a fully independent compliance committee composed of three legal experts and two independent members of the Wynn board of directors.

In September, federal authorities disciplined Wynn for regularly contracting with third-party independent agents acting as unlicensed money transmitting businesses to recruit foreign gamblers to the resort, according to the Justice Department. For the gamblers to repay debts to Wynn Las Vegas or have funds available to gamble there, the independent agents transferred the gamblers’ funds through companies, bank accounts and other third parties in Latin America and elsewhere, and ultimately into a Wynn-controlled bank account in the Southern District of California.

Funds deposited into the Wynn-controlled account were transferred into the Wynn cage account. According to federal attorneys, employees, with the knowledge of their supervisors, and working with the independent agents, eventually credited the Wynn account of each individual patron. The convoluted transactions enabled foreign gamblers at Wynn to evade foreign and U.S. laws governing monetary transfer and reporting.

The settlement with federal authorities was believed to be the largest ever for a casino.

Fifth-highest fine

If approved, the fine against Wynn would be tied for the fifth highest ever assessed by the state. Nevada fines associated with Wynn since 2019 total $35.5 million, including a record $20 million assessed in 2019 involving the company’s failure to properly investigate sexual harassment allegations brought by female employees.

Earlier this year, the Gaming Commission fined Resorts World Las Vegas $10.5 million in March and MGM Resorts International $8.5 million in April in separate money laundering cases.